Tellez-Cordova v. Campbell-Hausfeld (2004) 129 Cal.App.4th 577, 28 Cal.Rptr. 3d 744.
Gill Tellez-Cordova was a client of the Metzger Law Group who worked as a lamp-maker. He cut, sanded, and ground metal parts, working with die grinders, disc grinders, random orbital sanders, and cut-off saws. He developed interstitial pulmonary fibrosis as a result of exposure to airborne metal particles produced and released from the metal parts and from the discs, belts, and wheels used on the grinders, sanders, and saws. In addition to suing the manufacturers of the abrasive materials, the Metzger Law Group sued the manufacturers of the tools that Mr. Tellez-Cordova used because they were specifically designed to be used with abrasive wheels or discs to grind and sand metals, and the injurious exposures resulted from his use of the power tools. The defendants demurred, arguing that they were not liable because the harm (if any) was caused by the abrasive wheels, discs, and belts, and not by their tools. That is, they contended that the complaint failed to state a cause of action because there was no allegation that the tools disintegrated or devolved into toxic dust — only the abrasives and the materials being ground did that. The defendants based their argument on the component parts doctrine – that a manufacturer of a non-defective component part is not liable to one injured by the finished product into which the component part is incorporated. The trial court sustained the demurrer and dismissed the case as to the power tool manufacturers, and the Metzger Law Group appealed on behalf of Mr. Tellez-Cordova. The Court of Appeal reversed, holding that the component parts doctrine did not apply, because the defendants’ power tools were not component parts that could be used in a variety of finished products, but were instead manufactured tools which were specifically designed to be used with the abrasive wheels or discs they were used with, for the intended purpose of grinding and sanding metals, that the tools necessarily operated with those wheels or discs, that the wheels and discs were harmless without the power supplied by the tools, and that when the tools were used for the purpose intended by respondents, harmful respirable metallic dust was released into the air. This decision is important because it established that the manufacturer of a machine that is used with toxic chemicals and whose design creates the exposure to such toxic chemicals is liable for resulting toxic injuries just as is the manufacturer of the toxic chemicals that cause the injury.